Hazel Stevenson, Environmental Health Manager at Aberdeen City Council COVID-diary contribution accounts the incredible work carried out by the COVID-19 Expert Officers Group and also then answers questions on how her role at the local authority has changed.

The Work of the ETC19 Group

On the declaration of the public health coronavirus emergency, the Scottish Government introduced the Health Protection (Coronavirus) (Restrictions) (Scotland) Regulations 2020 (‘the Covid Regs’). It was obvious that this would fall to local authority Environmental Health and Trading Standards services to enforce. Discussions took place between the Chairs of Society of Chief Officers of Environmental Health in Scotland (SoCOEHS) and Society of Chief Officers of Trading Standards Scotland (SCOTSS) to agree the best way forward. 

In order to best coordinate our collective response to this duty, it was agreed that the way forward was to form an expert officers’ group who would lead on the interpretation of the regulations and guidance to ensure the consistency of application across Scotland.    

Within a week the ETC19 Group (Environmental Health and Trading Standards COVID-19 Group) was formed, I was invited to be a member and it met for the first time on 3rd April 2020. To date we continue to meet twice weekly.

Clearly this work could not be accomplished without involvement and cooperation of the other agencies involved in this response and so representatives from Police Scotland and HSE, as well as Scottish Government were invited to join.

Thematic subgroups were organised to respond to the demands placed on the group. These covered opinions and supporting information to local authorities; interpretation of the COVID Regs and Guidance; and establishing enforcement process, data sets and safe working practices guidance. 

Early success included:

  • Established the ‘Explain, Engage, Encourage and Enforce’ enforcement policy, agreed by all 32 Scottish local authorities and consistent with the approach adopted by Police Scotland
  • Agreed with Police Scotland how the duties set out under the regulations would be addressed by local authorities and Police Scotland
  • Agreed the demarcation of business sites with the Health & Safety Executive and local authority Environmental Health teams
  • Development of nationally agreed template for Prohibition Notices
  • Established working relationships with Scottish Government on various groups to progress policy and guidance for business
  • Agreed a suite of data sets which could be used to inform the Scottish Government and elected members of the levels of compliance work being carried out across Scotland  

The group immediately started to consider questions from local authorities and began producing FAQs which were circulated to all authorities and hosted, until recently, on the SCOTSS COVID web page. Where it is not possible to provide a response, the questions are fed back to the appropriate division of government to address. 

With every COVID Regs amendment or new piece of legislation, comes an interpretation from the ETC19 Group as to what this means and what it changes in terms of enforcement. This advice is circulated and used by all authorities.       

The agreed datasets quantifying the compliance assessment, business advice and reactive complaint work carried out by local authorities. It is collected on a fortnightly basis, complied, and published. They are also reported directly to the Scottish Government.

The group has been able to engage with the Scottish Government and address issues identified by enforcement officers and feed into and influence the thinking of government as the emergency has evolved. To do this the group established links with the various divisions within government that draft amendment regulations and the various pieces of sectoral guidance. 

 The Health Protection (Coronavirus, Restrictions) (Directions by Local Authorities) (Scotland) Regulations 2020 came into force on 28th August, followed by The Health protection (Coronavirus) (Restrictions and Requirements) (Scotland) Regulations 2020 on 14th September. Once again, the ETC19 Group has been providing coordination and consistency of interpretation of these new regulations. A subgroup was formed to address this and produce enforcement guidance and interpretation and templates for Direction and Prohibition Notices for use.

The group continues to focus on issues around interpretation of amendments to the regulations and statutory guidance, as well as answer questions from local authorities on local issues and original compliance scenarios which require analysis.

The ETC19 group was recently nominated for and awarded an ‘Outstanding Team Contribution’ award in the CTSi Hero Awards 2020.

My involvement of the group has provided a unique opportunity to work with colleagues from different sides of the regulatory landscape and understand their perspective on compliance.  At the same time, it has also offered a unique professional development opportunity, whilst being a challenging and enjoyable experience.


1.         Describe you work before the pandemic? 

My job title is Environmental Health Manager, which broadly entailed the delivery and overseeing of the Environmental Health duties within my Local Authority.

2.         What have you been doing since the pandemic started? 

I still have the same job, however, have also had additional duties.  At the beginning of the pandemic I was tasked with leading on the excess deaths across Grampian.  This included working with the three local authorities within this area as well as other external partners such as NHS, funeral directors, Police Scotland etc. I was also responsible for giving updates and assurance to the Grampian Local Resilience Partnership COVID-19.

I have been a member of the ETC19 Group since the issue of the first set of COVID regulations for businesses.

During the Aberdeen local lockdown I had to lead and ensure resource to provide the assurance visits of all hospitality premises which was required before lifting of the restrictions.  This was done jointly with my colleagues in Trading Standards.  I have continued ensure there is necessary resource to carry out all duties under the COVID regulations, compliance visits and complaints received.

3.         What are/were the challenges? 

Initially technology was a huge challenge, this is now greatly improved. As a manager the challenge is ensuring all staff feel supported and included as we have been home working since March with no access to the office.  

4.         Do you think any of these changes will last beyond the pandemic period? 

I think resource will always remain a challenge, there will be new challenges with some of the current ones remaining, it is clear that we will not go back to how things were pre -pandemic and this brings with it many positive and negative points.